ML18267A195
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| ML18267A195 | |
| Person / Time | |
|---|---|
| Issue date: | 09/18/2018 |
| From: | Dylanne Duvigneaud Programmatic Oversight and Regional Support Branch |
| To: | |
| Duvigneaud D | |
| References | |
| Download: ML18267A195 (7) | |
Text
Update on Interim Staff Guidance Decommissioning Funding Plans Materials Licensees
Interim Staff Guidance
Background
NMSS has been working on a draft ISG (ML18163A087) covering:
- Decommissioning Cost Estimate (DCE) reflecting current facility conditions
- Evaluating events since the last Decommissioning Funding Plan (DFP) approval
- Updates to financial instruments 2
Interim Staff Guidance DCE reflecting current facility conditions Part 70 licensees covering inventory:
- Licensee owned - contract in place where another party pays for packing, loading and shipping to an end destination
- Customer owned - customer retains legal title to the material and is contractually responsible for packing, loading and shipping to an end destination
- In-process inventory - justify a brief timeframe to process the material through into finished product, and then it will fall into licensee-owned or customer-owned inventory The draft ISG considers NEIs previous letter (ML16229A175) and NRCs response (ML16307A014) regarding DCE reflecting current facility conditions 3
Interim Staff Guidance Evaluating events since last DFP approval Make sure to include the 8 factors required by 30.35(e)(2), 40.36(d)(2) and CFR 70.25(e)(2):
- Spills of radioactive material impacting the subsurface
- Waste inventory that exceeds previous estimate
- Waste disposal costs that exceed previous cost estimated
- Facility modifications
- Changes in possession limits
- Remediation costs that exceed previous cost estimate
- Onsite disposal
- Use of a settling pond To reduce RAIs provide a narrative covering the 8 factors 4
Interim Staff Guidance Financial instruments
- Send original hard copy financial instruments directly to site PM not NRC Document Control as DC does not maintain original hard-copy documents
- For approval, NRC staff needs to review all agreements including any side letters to the financial instruments
- A template sight draft is being provided for staff use Banks typically require a sight draft to draw on the financial instrument
- Guidance on addressing CPAs opinion of off-balance sheet transactions for guarantees
- Supporting documents for Statements of Intent
- Verifying trust operations are regulated and examined by a Federal or State agency 5
Interim Staff Guidance Notices
- August 1st Federal Register Notice (FRN) published seeking comments on draft ISG requesting comments by September 17, 2018
- NEI contacted NMSS and indicated they would be holding a meeting with industry and requested to extend the comment period until after this meeting; therefore, on August 21st an FRN was published extending the comment period to October 5, 2018 6
Interim Staff Guidance Next steps
- Working towards publishing final ISG at the end of January 2019 7